Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
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